Creation of the International Taxation Division

March 29, 1982 REVENUE ADMINISTRATIVE ORDER NO. 03-82 SUBJECT : Creation of the International Taxation Division TO : All Internal Revenue Officers and Others Concerned I. Objectives : This Order is issued to implement more effectively the Reorganization of the Bureau under Executive Order No. 608 by eliminating overlapping functions and integrating homogeneous and interrelated activities involved in tax treaty implementation and interpretation. cdt II. Organization : To attain these objectives the International Taxation Division is created which shall be directly under the Legal Office. This Division shall be composed of Chief of Division, Assistant Chief of Division and an appropriate number of personnel to carry out its functions. III. Functions : The International Taxation Division shall perform the following functions: 1. Formulate and recommend policies and work programs and set-up standards, guidelines, procedures and techniques relating to tax treaty interpretation; 2. Prepare rules, regulations and other issuances relative to tax treaties; 3. Monitor commitments of the Commissioner with foreign countries not covered by tax treaty provisions; 4. Act on referrals on the proper implementation of tax treaty provisions and prepare rulings, opinions, or comments on such referrals; 5. Prepare digest or rulings, opinions and comparative tabulations on the relevant provisions of tax laws covered by tax treaties for dissemination to the public; 6. Prepare decisions on protested tax cases where the issues raised are questions of Law regarding tax treaties where there is no precedent; 7. Propose amendments and/or revisions to existing tax treaties and the implementing circulars, orders and regulations relating thereto; 8. Undertake a continuing study and research on various tax treaties including exchange of technical expertise and information; 9. Furnish all contracting states on any changes in the Philippine income tax laws and regulations; and 10. Perform such other related functions as may be assigned. IV. Repealing Clause : This Order revokes or supersedes the provisions of RAO 2-80 dated October 2, 1980 and RAO 1-81 dated January 27, 1981, insofar as it pertains to the above mentioned functions and all revenue issuances or portions thereof inconsistent with the provisions of this Order. V. Effectivity: This Order shall take effect immediately. RUBEN B. ANCHETA Acting Commissioner TAN: A5239-J1139-A-O